09-27-2026, 11:12 AM
@billnit, you have a live County Court claim now and, as you have already filed the AoS, you will need to file a defence by 4pm on Monday 12 October. I can provide you with a suitable defence.
You should, however, understand that ParkingEye are handling this claim themselves rather than passing it to one of the usual bulk-litigation solicitors. They presumably believe they have a case worth pursuing, so nobody should assume that simply filing a defence will make them go away. That does not mean the claim cannot be successfully defended.
There is already a potentially significant problem with their case. You have not identified the driver, so ParkingEye need to establish keeper liability under Schedule 4 of PoFA. Their NtK appears to fail paragraph 9(2)(e) because it does not contain the mandatory invitation to the keeper to pay the parking charge. This exact defect has already caused ParkingEye a problem in ParkingEye Ltd v Ghansah, M4FC56Q6 (2025), where the claim was dismissed in December 2025 because ParkingEye were pursuing the defendant as keeper and their NtK did not contain the invitation to pay required by PoFA 9(2)(e).
There is also the question of the amount claimed. The NtK demanded £100, yet ParkingEye have now claimed £130, before adding the £35 court fee and £50 legal representative's costs. Their Particulars do not explain where that additional £30 has come from or the contractual basis upon which they say it is owed. That will also be challenged.
One thing I do need you to clarify. ParkingEye's letter dated 5 January expressly states that they had sent you a Letter Before Claim and that they received your reply to that Letter Before Claim. Please find and post both that LoC and the response you sent to it, if you have them, as they may contain something relevant to the defence.
In the meantime, do not identify the driver and do not contact ParkingEye further.
You should, however, understand that ParkingEye are handling this claim themselves rather than passing it to one of the usual bulk-litigation solicitors. They presumably believe they have a case worth pursuing, so nobody should assume that simply filing a defence will make them go away. That does not mean the claim cannot be successfully defended.
There is already a potentially significant problem with their case. You have not identified the driver, so ParkingEye need to establish keeper liability under Schedule 4 of PoFA. Their NtK appears to fail paragraph 9(2)(e) because it does not contain the mandatory invitation to the keeper to pay the parking charge. This exact defect has already caused ParkingEye a problem in ParkingEye Ltd v Ghansah, M4FC56Q6 (2025), where the claim was dismissed in December 2025 because ParkingEye were pursuing the defendant as keeper and their NtK did not contain the invitation to pay required by PoFA 9(2)(e).
There is also the question of the amount claimed. The NtK demanded £100, yet ParkingEye have now claimed £130, before adding the £35 court fee and £50 legal representative's costs. Their Particulars do not explain where that additional £30 has come from or the contractual basis upon which they say it is owed. That will also be challenged.
One thing I do need you to clarify. ParkingEye's letter dated 5 January expressly states that they had sent you a Letter Before Claim and that they received your reply to that Letter Before Claim. Please find and post both that LoC and the response you sent to it, if you have them, as they may contain something relevant to the defence.
In the meantime, do not identify the driver and do not contact ParkingEye further.
Never argue with stupid people. They will drag you down to their level and then beat you with experience. - Mark Twain
